Responsible Gambling Policy
1.1 World Animal Protection have been protecting animals around the world from cruelty and abuse since 1950. In June 2014 we changed our name from World Society for the Protection of Animals (WSPA) to World Animal Protection. We believe that animals have a right to live free from pain by tackling cruelty and suffering worldwide.
1.2 To fund our vital work, we undertake a range of fundraising activities including direct marketing campaigns, events, competitions, raffle and lottery.
1.3 The World Animal Protection Weekly Lottery is managed by our External Lottery Manager (ELM), Sterling Lotteries Ltd under their society lottery brand – Unity.
1.4 The World Animal Protection Weekly Lottery is an important part of our fundraising. World Animal Protection promotes society lottery with all profits going towards our charitable aims.
1.5 World Animal Protection is committed to ensuring that it operates in a secure, fair and socially responsible way and to encouraging responsible gambling amongst its players.
1.6 World Animal Protection is licensed with the Gambling Commission who regulate gambling in Great Britain and World Animal Protection will always adhere to the legal requirements of the Gambling Act 2005.
1.7 The Gambling Commission regulates gambling in the public interest. The regulatory framework introduced by the Gambling Act 2005 is based on three licensing objectives:
(a) Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime.
(b) Ensuring that gambling is conducted in a fair and open way.
(c) Protecting children and other vulnerable people from being harmed or exploited by gambling.
1.8 World Animal Protection hold the necessary licenses to conduct its lottery, both a Remote Lottery Licence: licence number 000-004984-R-310886-009 (internet, telephone or any other electronic or technological method of communication) and a Non-Remote Lottery Licence: licence number 000-004984-N-304950-012 (face to face commitments or by normal letter post).
1.9 This document sets out World Animal Protection’s approach to ensure we approach any gambling activities in a socially responsible way.
2.1 World Animal Protection are committed to conducting its lottery in a fair and open manner.
2.2 World Animal Protection will ensure that all Terms and Conditions for the lottery are fair and open and are published online and are available to all participants who may request them. Players in the lottery will be notified of any changes to these terms before they come into effect..
2.3 All winners are notified within a reasonable period of time following the lottery draw, and all reasonable effort is made to award prizes to winners. Any unclaimed prizes will be dealt with in accordance with the relevant Terms and Conditions.
2.4 Winning numbers will be published on the World Animal Protection Weekly Lottery website: www.worldanimalprotection.org.uk/lottery.
2.5 Where our lottery is conducted by an External Lottery Manager (ELM) on our behalf, World Animal Protection will ensure that the ELM also adheres to these requirements.
3.1 Protecting children
3.1.1 It is illegal for any person under the age of 16 to enter a lottery.
3.1.2 World Animal Protection will not permit sales of tickets to any person in a vulnerable circumstance or any person under the age of 18 to participate our lottery.
3.1.3 World Animal Protection will not mail anyone with tickets who we know to be under the age of 18.
3.1.4 We will ensure that our Terms and Conditions, advertising, entry instructions, welcome material (including tickets) and website for our lottery all advertise the minimum legal age and we will make efforts try and avoid placement of advertising where children may be vulnerable.
3.1.5 World Animal Protection staff, and where applicable any third-party suppliers acting on our behalf who are selling tickets or entries through face to face fundraising, are trained to request proof age from any person taking part who appears to be under the age of 18.
3.1.6 All new entries to our lottery will go through an age verification check, permitting only those aged 18 and over to enter. Thus, any lucky winners of our lottery will receive their prizes.
3.1.7 In the unfortunate circumstance where a person under the age of 18 is found playing our lottery, they will forfeit their winnings and their entry fee will be returned to them.
3.1.8 Where entries can be purchased online or by other means other than face to face or telemarketing, we will:
(a) Advertise clearly that you must be 18 or over to purchase an entry.
1 Advertise clearly that underaged gambling is an offence.
2 Require date of birth to verify legal age before lottery entry is purchased.
3 All new players will go through age verification checks before their entry is completed.
3.2 Protecting vulnerable people
3.2.1 World Animal Protection will politely refuse to accept further participation in their lottery from any person who has been discovered to be vulnerable, or are suspected of being vulnerable, typically by recommending that the customer speaks to a carer or family member before proceeding further with their entry.
3.2.2 World Animal Protection will monitor ongoing contact and communications with people to ensure they can detect any behaviour which may indicate whether a person’s vulnerability becomes evident after initial sign up.
3.2.3 It is of the highest importance that people can make a fully informed decision before playing. World Animal Protection will ensure that its staff, and those of its ELM if used or any third-party service supplier are trained to be able to reasonably assess this when communicating with a potential player
4.1 World Animal Protection is committed to preventing gambling from being a source of or associated with crime or disorder, or being used to support crime.
4.2 World Animal Protection will refuse to contract any agencies or contractors who are suspected of being associated with any potential or actual criminal activities.
4.3 World Animal Protection will restrict the number of entries for our weekly lottery to a maximum of two £1 entries per week per player.
4.4 World Animal Protection will restrict the number of memberships to our lottery to a maximum of 1 per player.
4.5 We reserve the right to reject any entry to our lottery should we suspect criminal activity.
4.6 We will report any actual or suspected criminal activity in line with the Proceeds of Crime Act 2002.
4.7 Sellers on non-remote subscription based weekly lottery tickets, whether by door-to-door or kiosk are not permitted to take cash or cheque in lieu of payment, thus further minimising risk.
5.1 World Animal Protection wants to encourage people to gamble responsibly and seek help should their gambling become a problem.
5.2 World Animal Protection is committed to ensuring that information about how to gamble responsibly and how to access information and help in respect of a problem gambling is readily available to all.
5.3 We impose limits on the value of entries that can be purchased by a player and we reserve the right to refuse any requests for additional entries.
5.4 World Animal Protection is a member of the Lotteries Council which makes an annual donation to Gambleaware on behalf of its members.
5.5 World Animal Protection will adhere to the advertisement rules laid out by the Committee of Advertising Practice which can be summarised as:
(a) Not encourage gambling that may lead to socially irresponsible acts or could lead to financial, social or emotional harm.
1 Not exploit children or other vulnerable people.
2 Not suggest gambling can solve financial problems or debts.
3 Not suggest gambling can increase attractiveness or sexual success.
4 Not link gambling to youth culture or attempt to attract young persons to gamble.
5.6 Keeping gambling under control
Most people do gamble responsibly and gambling in moderation is considered acceptable, but to help keep gambling under control it is recommended that players:
(a) Remember that taking part is for fun and not as a means of investing or making money.
(b) Set strict limits on how much time and money to spend, before playing.
(c) Only gamble with money you can afford to lose.
(d) Don't spend more money on gambling in the hope that it will be won back again.
(e) Keep up other interests and hobbies and don't let gambling take over your life.
(f) Don't gamble to escape from stress or boredom or if you are depressed or upset.
5.7 Signs that gambling is becoming a problem
People do not start out as problem gamblers. It starts as a fun activity but for some it can become a problem. If you are concerned about the amount you are gambling, or you are concerned about a friend or relative, then the following may help give you some guidance:
(a) Uncontrolled spending.
(b) Borrowing money and not being able to pay it back.
(c) Changes in personality or behaviour.
(d) Changes in mood, bouts of anger or displays of anxiety or stress.
(e) Significant amounts of time spent gambling.
(f) Concealing or lying about gambling behaviour.
(g) Gambling impacting on relationships with family and friends.
(h) Withdrawal from family or other social activities.
(i) Spending excessive amounts of time on a computer.
(j) No apparent interests or leisure pursuits.
(k) Absence from school, college or work.
For more information and help about problem gambling:
Call the National Gambling Helpline (Freephone): 0800 8020 133. Free and confidential. Open 8am-Midnight, 7 days a week.
Available software which blocks access to gambling websites: Gamcare.
Other organisations providing help and advice
A full list of organisations which provide help and advice is available through the Gambling Commission.
6.1 World Animal Protection has put into effect procedures for self-exclusion and take all reasonable steps to refuse service to or to otherwise prevent any person who has entered a self-exclusion agreement from participating in gambling.
6.2 If a person has requested a self-exclusion from gambling:
(a) World Animal Protection will take all reasonable steps to prevent any marketing material being sent to a self-excluded person and will remove the name and details of a self-excluded person from any lottery mailing lists on the database by flagging that person as someone to whom must no longer receive marketing material (specifically gambling related).
(b) World Animal Protection will close any player accounts belonging to a person who has entered a self-exclusion agreement and return any funds held in the player account.
(c) World Animal Protection ensures that a person who has self-excluded cannot gain access to gambling by flagging that person’s record as well as holding a register of those excluded with appropriate records (name, address and other details that may be held by the operator). There will also be staff training to ensure that staff can enforce the systems.
6.3 World Animal Protection’s self-exclusion procedure requires people to take positive action to self-exclude. World Animal Protection’s self-exclusion form is available on the World Animal Protection website and by contacting World Animal Protection Supporter Services. This must be printed, completed, signed and returned to Sterling Lotteries (external lottery manager working on behalf of World Animal Protection) for the self-exclusion to come into effect.
6.4 To enable a person to make the decision on whether to self-exclude, World Animal Protection will provide or make available sufficient information about what the consequences of self-exclusion are. These details are available on the World Animal Protection self-exclusion form and the World Animal Protection website go to ‘Rules’ – Section 10 ‘Self Exclusion’.
6.5 World Animal Protection encourages the people to consider extending their self-exclusion to other charities or companies that provide similar gambling facilities.
6.6 People are given the opportunity to discuss self-exclusion in private, where possible.
6.7 World Animal Protection takes self-exclusions from gambling very seriously and takes steps to ensure that:
(a) The self-exclusion period is a minimum of six months and gives player the option of extending this to a total of at least five years in increments of six months.
(b) Any person who has decided to enter a self-exclusion agreement with World Animal Protection is given the opportunity to do so immediately without any cooling-off period. However, if the person wishes to consider the self-exclusion further (for example to discuss with problem gambling groups such as GamCare) that person may return later to enter self-exclusion.
(c) At the end of the period chosen by the person (which will be for a minimum of six months), the self-exclusion remains in place, unless they take positive action to gamble again. No marketing material should be sent to that person unless they have taken positive action to gamble again, and has agreed to accept such material.
(d) The person’s record remains flagged as ‘do not contact’ until they contact World Animal Protection’s ELM, Sterling Lotteries to request the removal of the flag. Flags will only be removed if the person’s exclusion period has ended.
(e) Where a person chooses not to renew the self-exclusion, and makes a positive request to begin gambling again, the player is given one day to cool off before being allowed access to gambling facilities. The contact must be made via telephone or in person. The lottery entry will only be processed if the person’s exclusion period has ended.
6.8 World Animal Protection retains the records relating to a self-exclusion agreement at least until the agreement has been formally ended.
6.9 The Gambling Commission does not require World Animal Protection to carry out any assessment or make any judgement as to whether the previously self-excluded person should again be permitted access to gambling. The requirement to take positive action in person or over the phone is purely to check that the person has considered the decision to:
(a) Access gambling again and allow them to consider the implications; and
(b) Implement the one-day cooling-off period and explain why this has been put in place.
7.1 All complaints relating to World Animal Protection Weekly Lottery will be handled in accordance with the World Animal Protection Complaints Policy which is in line with our membership of the Fundraising Regulator which requires us to comply with the Institute of Fundraising (IoF) Code of Practice.
7.2 World Animal Protection will:
- Make the Complaints process available to people via the World Animal Protection Weekly Lottery Website
- Handle all complaints in accordance with the Complaints Policy. Policy available on request.
- Will escalate complaints to an independent third party or ADR provider (for unresolved complaints).
- Annually report to the Gambling Commission on the number and status of all complaints.
8.1 Financial requirements
8.1.1 All money received by World Animal Protection in payment for entries to World Animal Protection Weekly Lottery will be handled in accordance with World Animal Protection finance and cash handling policies.
8.2 Information requirements
8.2.1 World Animal Protection will make all reasonable efforts to ensure that the Gambling Commission are provided with any information that they know relates to or suspect may relate to an offence under the Gambling Act 2005, including an offence resulting from a breach of licence condition or a code provision having the effect of a licence condition.
8.2.2 World Animal Protection will make all reasonable efforts to ensure that all key events that could have a significant impact upon the nature or structure of a licensee's business are notified to the Gambling Commission as soon as is reasonable and in any event within five working days of the licensee becoming aware of the event's occurence. Key events are those concerning operater status, relevant persons and positions, financial events, legal or regulatory proceedings or reports and gambling facilities.
8.2.3 Monthly Lottery Submissions will be completed by World Animal Protection and will be submitted to the Gambling Commission within 3 months of the date of each lottery draw.
8.2.4 World Animal Protection will submit an annual Lottery Regulatory Return to the Gambling Commission.